A COMMITMENT TO OUR CUSTOMERS, EMPLOYEES AND SOCIETY

For years we have accompanied thousands of doctors, specialists and pharmacies in their daily practice, aware that they can contribute to improving the quality of the citizen’s healthcare and the services offered by the healthcare system. We make our clients’ work easier and less time-consuming with effective and innovative solutions which enable a significant reduction in costs and an increase in personal and medical attention to the health of the patients.

Every day, trained and competent people endeavor to support, disseminate and improve the products intended for our customers. This implies continuing education so as to be competitive and ready to foresee the needs of a market in which we aim to maintain our established industry leadership.

We pursue this goal while respecting the principles of correct conduct, the transparency of managerial decisions and our responsibilities to the various stakeholders.

Correctness also translates into a constant ethical commitment, both internally and externally. For this reason, we certify all our processes to guarantee the quality of customer service and respect for the environment. We engage in the full protection of the rights of workers, from healthcare to contracts.

Our attention is also focused on converting our positive economic results into support for human dignity and suffering with actions of solidarity, such as those we have already carried out with Action Aid, Lega del Filo d'Oro, Doctors Without Borders and the Italian Red Cross.

Code of Ethics

CompuGroup Medical SE acknowledges the obligation to behave as a responsible member of society and we shall always achieve our goals through ethical behavior. From this conviction, we provide this document - Code of Ethics - to state the specific requirements for business practice and personal conduct. The Code of Ethics applies to all who work for CompuGroup Medical, including managers and staff of all subsidiaries, and to all our suppliers, partners, consultants and others who act on CompuGroup Medical's behalf.

With this Code of Ethics, we are obliged to respect our customers, shareholders, employees, contractors and our environment and we confess that we always act honestly, fairly and professionally.

1. Compliance with Law, Regulations and Standards

All CompuGroup Medical representatives must act in conformity with the laws and regulations in Italy, Germany and in all the jurisdictions in which the company operates.

2. Equality and diversity

CompuGroup Medical will show respect for all individuals and make active efforts to ensure a good working environment characterized by equality and diversity. CompuGroup Medical does not accept any form of discrimination. Discrimination includes all unequal treatment, exclusion or preference on the basis of race, gender, age, disability, sexual orientation, religion, political views, national or ethnic origin or other similar circumstances that result in the setting aside or compromising of the principle of equality.

3. Code of personal conduct

CompuGroup Medical expects all representatives to treat everyone with whom they come into contact through their work or work related activities with courtesy and respect. All representatives must refrain from all conduct that can have a negative effect on colleagues, the working environment or CompuGroup Medical. This includes any form of harassment, discrimination or other behavior that colleagues or business associates may regard as threatening or degrading. All representatives must not behave in a manner that can offend local customs or culture.

4. Conflict of interest

All representatives must behave impartially in all business dealings and not give other companies, organizations or individuals improper advantages. It is not allowed to become involved in relationships that could give rise to an actual or perceived conflict with CompuGroup Medical's interest or could in any way have a negative effect on their own freedom of action or judgment.No one must work on or deal with any matter in which they themselves, their spouse, partner, close relative, or any other person with whom they have close relations, has a direct or indirect financial interest. Nor may any representative work on or deal with any matter where there are other circumstances that might undermine trust in the employee’s own impartiality or to the integrity of the work.It is forbidden to hold office, perform functions or act on behalf of competing companies, suppliers, or companies that exert a form of domination or control over competing companies. Employees should consult CompuGroup Medical before accepting any office, co-option or appointment outside the Company that may condition their independence and professional dedication to the Company.

5. Corruption, bribery and trading in influence

CompuGroup Medical is against all forms of corruption, bribery and trading in influence and will make active efforts to ensure that it does not occur in the Group’s business activities.CompuGroup Medical prohibits the offer, gift, or acceptance of a bribe in any form, including kickbacks, on any portion of a contract payment, or the use of other routes or channels to provide improper benefits to customers, agents, contractors, suppliers or employees of any such party or government officials.CompuGroup Medical also prohibits an employee from arranging or accepting a bribe or kickback from customers, agents, contractors, suppliers, or employees of any such party or from government officials, for the employee’s benefit or that of the employee’s family, friends, associates or acquaintances.The prohibition against bribes and trading in influence applies both to the party giving or offering an improper advantage and to the party who requests, receives or accepts such advantage. For the matter to be considered illegal, it is sufficient that a demand or an offer of improper advantage is made.CompuGroup Medical recognizes that facilitation payments (payments where the recipient is using the power of his or her official position and where the consequence of not paying can be out of all proportion to the small payment demanded) are a form of bribery and subject to the same rules as listed above.

6. Gifts, hospitality and expenses

CompuGroup Medical prohibits the offer or receipt of gifts, entertainment or expenses whenever such arrangements could affect the outcome of business transactions and are not reasonable and bona fide expenditures.All CompuGroup Medical representatives must consider the criteria listed below to determine if gifts, hospitality or reimbursed expenses comply with the Code of Ethics.

Made for the right reason: the gift or hospitality should be given clearly as an act of appreciation;

No obligation: the gift, hospitality or reimbursement of expense does not place the recipient under any obligation;

No expectations: expectations are not created in the giver or an associate of the giver or have a higher importance attached to it by the giver than the recipient would place on such a transaction;

Made openly: if made secretly then the purpose will be suspect;

Accords with stakeholder perception: the transaction would not be viewed unfavorably by stakeholders if it were made known to them;

Reported: the gift, hospitality or expense should be reported to management;

Reasonable value: the size of the gift is small; the value of the hospitality or reimbursed expense accords with general business practice;

Appropriate: the nature of the gift, hospitality or reimbursed expense is appropriate to the relationship and accords with general business practice;

Legality: it conforms to the laws of the country where it is made;

Conforms to the recipient’s rules: the gift, hospitality or reimbursement of expenses meets the rules or code of conduct of the receiving organization;

Infrequent: such giving or receiving is not a regular happening between the giver and the recipient.

7. Charitable contributions and sponsorships

CompuGroup Medical shall ensure that charitable contributions and sponsorships are not being used as a subterfuge for bribery. CompuGroup Medical will publicly disclose all its charitable contributions and sponsorships.

8. Political contributions

CompuGroup Medical, its employees or agents shall not make direct or indirect contributions to political parties, organizations or individuals engaged in politics, as a way of obtaining advantage in business transactions. CompuGroup Medical will publicly disclose all its political contributions.

9. Enforcement of Code

This Code of Ethics applies to all those who work for CompuGroup Medical, including managers and staff of all subsidiaries, and to all our suppliers, partners, consultants and others who act on CompuGroup Medical's behalf.Violations of any of the principles listed in this document will cause consequences and can potentially lead to dismissal. Suspicion of a violation of the Code of Ethics shall be reported to a superior.The Code of Ethics is posted on the company's own website and is accessible to everyone. New employees will be informed about the Code of Ethics by the Personnel Department.

10. Liability disclaimer

None of the provisions in this document are intended to be construed as creating any right(s) enforceable by a third party and all third party rights implied by law are, to the extent permissible by law, excluded.